Comprehensive Privacy Notice

1. IDENTITY AND DOMICILE OF RESPONSIBLE PERSON

This privacy notice governs the processing of personal data by EUROPE COLLECTION SERVICES, S.A. DE C.V., hereinafter referred to as “EUROPE”, with address located at, domiciled at Miguel Angel de Quevedo 1023, department 102, colonia El Rosedal, Delegación Coyoacan, in Mexico City. 04330, , as Responsible Person, who will perform treatment to personal data concerning you, the owner of your personal data, in order to protect your privacy and right to information self-determination, as foreseen under the Federal Law of Protection of Personal Data in Possession of Private Persons (Federal Law of Protection of Personal Data in Possession of Private Persons, hereinafter LFPDPPP), its Regulations and Privacy Notice Guidelines issued by the Department of Economy (hereinafter, Ordinances).

2. DEFINITIONS

For the purposes of this Notice, definitions of the terms “Personal Data”, “Sensitive Personal Data”, “Days”, “Treatment”, “Owner of Data”, “Responsible Person”, “Transfer”, “ARCO Rights” – “Access Rights”, “Rectification Right”, “Cancelation Right”, “Opposition Right”; “Cookies”, as well as all other elements foreseen under the Notice will have the same meaning as that assigned thereto by the Ordinances.

3. PERSONAL DATA COLLECTED AND TREATED BY US

EUROPE collects and processes Personal Data listed below:

4. PURPOSES

EUROPE processes your personal data with the purpose of carrying out the activities and management aimed at complying with the obligations arising and derived from any business and/or legal relationship we establish with you and that we consider as primary purposes, which include:

Additionally, we shall process your personal data for other secondary purposes, which do not give rise to or are necessary for the legal and/or business relationship we may establish with you, which include:

5. OWNER CONSENT.

For the purposes of that provided for under Ordinances, you hereby recite: i) that this Notice has been made of your knowledge by EUROPE prior recollection and/or treatment of your Personal Data, ii) that you have read, understood and agreed the terms contained in this Notice regarding collection and treatment of your patrimonial and/or financial data, therefore, if supplied you will autographically enter your name and signature at the foot of this document or else you will express your consent through dialogue windows enabled in our websites. The above on he grounds of articles 8 and 9 of LFPDPPP, as well as in terms of articles 11, 12, 14, 15, 16 of the Regulations, without detriment of exception cases foreseen under articles 10 and 37 of LFPDPPP authorizing us to treat your Personal Data and transfer the same in order to allow compliance with our obligations in legal or contract terms or by virtue of the legal relationship, both current and/or future, with you. For collection, treatment and transfer of your Personal Data, when not of financial or patrimonial nature, you will provide your implied consent in terms of this Notice upon your not objecting or opposing its contents within the next 48 hours of Personal Data collection and this Notice has been made available to you through different media included by publication through our Website.

6. TRANSFER OF DATA TO THIRD PARTIES.

Having read, understood and agreed to the terms contained in this Privacy Notice, Owner consents to the transfer of Personal Data thereof by Responsible Person or any Person in Charge to domestic or foreign third parties, in the understanding that treatment such domestic or foreign third parties may give to Owner’s Personal data must adhere to the contents of this Privacy Notice. For the purposes of that provided for in this Section but subject to the provisions of last paragraph thereof, Responsible Person informs Owner that in order to deliver products, services and solutions to customers, consumers and all other service users, Responsible Person and/or Persons in Charge have executed or will execute a number of business agreements with suppliers of products and service providers both in domestic territory as well as abroad to provide services including, among other: e-mail; database management and administration; automated treatment of Personal Data and storage; customer support call center; e-mail authentication and validation; telemarketing; credit card terminals; e-invoicing; marketing; audit services and other similar services. Owner’s authorization granted in terms hereof authorizes Responsible Person and/or its Persons in Charge to transfer Owner Personal Data to such service providers in the understanding that such service providers be bound, in terms of applicable contract, to maintain confidentiality of Personal Data made available thereto by Responsible Person and/or its Persons in Charge and to observe this Privacy Notice. Responsible Person and/or its Persons in Charge may transfer Owner collected Personal Data to any other company of the same corporate group to which Responsible Person belongs operating under the same internal processes and policy, whether in domestic territory or abroad for their treatment to the same ends as described in this Privacy Notice. Such Personal Data may also be transferred thereby to alternate third parties providing their support to comply with agreements or legal relationships with Owner.
Your personal data may be transferred, stored and processed in a country other than the place of delivery. If we do, we will be transferring your information in accordance with applicable information protection laws. We will adopt measures to protect personal data regardless the country of storage or where it is transferred to. We have prompt procedures and controls for the procurement of such protection.
We reserve ourselves the right to transfer your Personal Data upon the sale or transfer of all or some of our business or assets. Should such sale or transfer occur, we will do our best to invite the ensuing business owner to use Personal Data in terms with this Notice. Should, following transfer, you not be willing to have your Personal Data processed you should contact the new business owner.
Notwithstanding the provisions of this Section or anywhere else in this Privacy Notice, Owner acknowledges and accepts that Responsible Person requires no authorization or confirmation from such Owner for the purposes of domestic or international transfers of Personal Data in cases foreseen under Article 37 of the Federal Law of Protection of Personal Data in Possession of Private Persons or in any other case except as foreseen in same applicable law or any other.

7. PROCEDURE TO EXERCISE ARCO RIGHTS AND CONSENT REVOCATION

In order to exercise ARCO Rights, Owner or Owner’s representative must file an access, rectification, cancellation or opposition request providing the following information and documents:

For Personal Data rectification purposes, pertinent Owner must also indicate modifications to be made and contribute documents in support of such request.
For filing, registration and attention of requests to exercise access, rectification, cancellation and opposition rights regarding own Personal Data, and to limit use or disclosure of such data and all other rights foreseen under Federal Law of Protection of Personal Data in Possession of Private Persons, you may contact: e-mail: datospersonales@europe-collections.com (This e-mail is only for request to exercise ARCO rights. Request of any other nature will be disregarded). Responsible Person or Appointed Individuals will answer to pertinent Owner within twenty business days as from the date access, rectification, cancellation or opposition request was filed or as of the date of adopted resolution to the effect that, if applicable, the same is to be executed within fifteen days following the date the answer is notified to Owner. When about Personal Data access requests, Responsible Person or Appointed Individuals will proceed to delivery thereof prior demonstration of identity of requesting party or his/her legal representative, as the case may be. Above described terms may be only extended in terms of the Federal Law of Protection of Personal Data in Possession of Private Persons.
Delivery of Personal Data will be without consideration, you will only have to pay justified expenses for sending or reproducing copies or other formats. Should Owner file a second request for a term shorter than twelve months, Owner should pay costs at the rate equivalent to 1.5 days of Daily Minimum Wages in force in Mexico City in terms of the Federal Law of Protection of Personal Data in Possession of Private Persons, unless there are substantial modifications to the Privacy Notice motivating new consultation.
For the purposes of Personal Data cancellation requests, in addition to the provisions of this Privacy Notice, the provisions of Article 26 of the Federal Law of Protection of Personal Data in Possession of Private Persons will apply, including identified Personal Data cancellation exceptions.
Filing of Personal Data opposition request by the Owner thereof will entitle Responsible Person to oppose the use of Personal Data delivered to the counterparty as Owner thereof.

8. PERSONAL DATA DEPARTMENT.

Any questions, comments or information about our Privacy Notice may be directed to our Personal Data and ARCO Rights Administration Committee at: e-mail: datospersonales@europe-collections.com (This e-mail is only for requests to exercise ARCO rights. Request of any other nature will be disregarded). For the purposes of that provided for under fraction I, Article 16 of the Federal Law of Protection of Personal Data in Possession of Private Persons, the domicile of Responsible Person is that provided for in this Section 6 of this Privacy Notice .

9. LIMIT OF USE AND DISCLOSURE OF INFORMATION.

EUROPE will maintain your Personal Data as long as necessary to manage the business and/or legal relationship with you as well as to maintain records in terms of that provided for under the LFPDPPP, its Regulations, and applicable commercial, administrative and tax laws. Personal Data collected by EUROPE are protected by administrative, technical and physical security measures appropriate against unauthorized damage, loss, alteration, destruction or use, access or treatment, in accordance with the provisions of the LFPDPPP and its Regulations.
To limit use and disclosure of your Personal Data, please e-mail our Personal Data Department at datospersonales@europe-collections.com notifying your request. You may also elect to be excluded from our electronic mailing list using dialogue windows enabled to such effect in our website. You may also register in the Public Registry of Consumers in the Federal Consumer Protection Agency (http://rpc.profeco.gob.mx) to prevent any advertising, promotion and/or product offering phone calls.
Collection of data when browsing EUROPE websites
EUROPE may collect Personal Data through its Website or using automatic data capture tools. Amongst automatic data capture tools used by EUROPE in its Websites are cookies, Web beacons and links in e-mails.
Use of Cookies.- EUROPE’s website requires, for accurate performance, enabling cookies in your web browser. Cookies are small data files transferred by the Website to your computer or mobile device’s hard disk when browsing our websites. Most browsers automatically enable cookies by virtue of their preset configuration, you may adjust your browser preferences to accept or reject cookies. Cookie deactivation may disable a function of EUROPE websites functions or avoid accurate display. Should you prefer to eliminate cookies you may eliminate them at the closing of each web browser session.
These cookies may be disabled. To learn how to, you may follow the following electronic link or address:

Use of Web beacons.- Also known as web tags, pixel tags and clearGIFs.- EUROPE may use Web beacons in its websites and HTML-formatted e-mails, whether individually or in combination with cookies to collect information on the use of websites and interaction with e-mail. A Web beacon is an electronic image, of a single pixel (1x1) or GIF that is able to recognize information processed by your computer such as cookies, time and date the site and different sections were viewed.
Links EUROPE e-mails.- e-mails with links allow EUROPE to learn whether you activated such link and visited the destination webpage, and such information may be included in your profile.
Protection to minors or incapacitated persons: EUROPE does not collect nor gives treatment to Personal Data of minors or incapacitated persons and encourages parents and/or tutors to actively participate in on-line activities of their children and/or represented. Should EUROPE believe that a minor or an incapacitated person has provided Personal Data in contravention to this Notice, we will immediately eliminate such Personal Data. Should you become knowledgeable of such Personal Data being provided by an underage minor or by an incapacitated person, please e-mail us to: datospersonales@europe-collections.com

10. AMENDMENTS to NOTICE.

EUROPE reserves itself the right to update this Notice for the purposes of reflecting changes in our data protection practice as a result of our continuous improvement process as well as changes in laws, regulations and administrative provisions that may apply. Please often review the contents of our Privacy Notice at our website, there we will publish any amendments implemented and date of last update.